Revenue eBrief No. 011/25
15 January 2025
Review of Opinions or Confirmations
Tax and Duty Manual Part 37-00-41 - Review of Opinions or Confirmations - has been updated to provide guidance to taxpayers who wish to continue to rely on an opinion or confirmation issued by Revenue in the period 1 January and 31 December 2019, in respect of a transaction, period or part of a period, on or after 1 January 2025.
A taxpayer who wishes to continue to rely on such an opinion or confirmation is required to make an application for its renewal or extension on or before 31 March 2025.
The Tax and Duty Manual has also been updated to clarify that if the matter dealt with in the original opinion/confirmation has subsequently been clarified in Revenue guidance a request of a renewal of the opinion/confirmation will not be accepted.